Thank you for the opportunity to comment on the proposed changes in the law that would allow dental assistants or dental assistant II (DAII) to scale type 1 periodontal patients. I am STRONGLY OPPOSED to this change in the law as a professional educator and as a consumer. According to Oral Health in America: Report of the Surgeon General (2000) most adults show signs of gingival and periodontal diseases and this prevalence increases with age.  My concern is that dental assistants are trained on-the-job to assist the dentist, with no standardized formal curriculum or national benchmark to verify competence in intra oral procedues. Dental assistants are not licensed, nor are they required to maintain competence via annual continuing education. People in Virginia deserve greater access to quality oral healthcare. This proposed change in the law does nothing to address access to quality care for people who do not receive dental care since most of those are outside of the private dental practice setting. In terms of health economics, the proposed change in the law will not save consumers money since dentists likely will continue to charge the same fees for this service and insurance companies  likely will continue to reimburse at the same rates. Furthermore, patients will erroneously believe that they are disease free when actuality, they still may be at risk for disease progression.

Yes, dentists are ultimately responsible for the actions of dental assistants and dental hygienists, but dental hygienists are also responsible under the law for a defined scope of practice by virtue of licensure. Dental hygienists require less supervision than dental assistants and in today’s busy dental practices, dentists have little time to train or supervise dental assistants doing intraoral procedures on patients.  If the Board of Dentistry and the State Legislature is truly concerned about standards of healthcare, and  improved access to healthcare to for underserved and vulnerable populations who do not receive care, then dental hygienists who must meet national and state standards and demonstrate competence  to attain a license to practice via:

·         graduating from a program accredited by the American Dental Association Commission on Accreditation,

·          passing the National Board Dental Hygiene Examination and Regional Examinations, and

·          mandatory  15 hours of continuing  education annually to maintain licensure to practice

should be working collaboratively with dentists  and dental assistants to meet the population need, and each has an important role to play.  Dental hygienists specialize in patient screening and assessment, oral disease prevention, patient education, therapeutic scaling, and periodontal maintenance care and follow-up.  Most notable is the fact that oral disease prevention is proven to cut healthcare costs.  Let us continue to protect the health and welfare of the people of Virginia by supporting professionals who are formally educated and licensed to provide safe, effective, evidence-based preventive and therapeutic periodontal services.

Thank you,